New 415 rules

[FAPInJax]

How do the new interest rates impact the calculation of the 415 limits???

Do we have separate computations for lump sums and forms of annuity??

Assume a participant is at the maximum benefit at age 62. The reduction to a monthly benefit payable at 55 is performed using (ignoring actuarial equivalent issues) 5% and GAR???

The lump sum value of this benefit is then computed using the 'new' 5.5% interest rate??

I thought the participant was entitled to the greater of the lump sum using actuarial equivalent or GAR94 and the 30 year Treasury rate. This lump sum was limited by the new lump sum limit using 5.5% for everything.

I thought this was pretty clear until we had a little discussion and in rereading the regulation it is not at all clear that the 5.5% is applied for the determination of the maximum benefit BUT just for the lump sum.

Any responses are appreciated.

[Blinky the 3-eyed Fish]

Sounds like DB questions to me.